2015/08/11 City Council Resolution 2015-131A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROHNERT PARK
AUTHORIZING AND APPROVING THE CITY OF ROHNERT PARK UPDATING AND
REAFFIRMING THE CITY'S POLICY AND COMPLAINT PROCEDURE AGAINST
HARASSMENT, DISCRIMINATION AND RETALIATION
WHEREAS, Title VII of the Civil Rights Act of 1964 (Title VII) is the federal law
that prohibits discrimination, harassment, and retaliation in the workplace and the California
Fair Employment and Housing Act (FEHA) establishes the state prohibition against
harassment, discrimination and retaliation based on a protected status; and
WHEREAS, the City of Rohnert Park is committed to promoting and maintaining a
work environment in which all individuals treat each other professionally and with mutual
respect; and
WHEREAS, staff recommends that the City Council adopt the updated City of
Rohnert Park Policy and Complaint Procedure Against Harassment, Discrimination and
Retaliation in compliance with Title VII and FEHA attached as Exhibit "A ".
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Rohnert
Park that it does hereby authorize and approve the updated City of Rohnert Park Policy and
Complaint Procedure Against Harassment, Discrimination and Retaliation attached hereto as
Exhibit "A" and incorporated by this reference.
BE IT FURTHER RESOLVED that this Resolution supersedes and replaces
Resolution no. 2007 -117.
DULY AND REGULARLY ADOPTED this 11"' day of August, 2015„
CITY �. F 1(T N E I:I'I' PA R 'I "
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s
Amy O,,, . 11dI101u, Mayor
ATTEST:
o,�1 iiie M. Buergler, 'Aty l.° l� M
Attachment: Exhibit A
CALLINAN: ME MACKENZIE: AyC STAFFORD: AyC BELFORTE:PBSENT AHANOTU: M
AYES: ( y ) NOES: ( 0 ) ABSENT: ( I ) ABSTAIN: ( p )
CITY OF ROHNERT PARK
CITY COUNCIL POLICY
SUBJECT
POLICY AND COMPLAINT PROCEDURE AGAINST
HARASSMENT, DISCRIMINATION AND
RETALIATION
PURPOSE
POLICY NO., I RESO. N
440.20.1 1 2015 -131
23
EFF. DATE
AUGUST 12, 2015
PAGE 1 OF 9
The purpose of this Policy is to: establish a strong commitment to prohibit and
prevent discrimination, harassment, and retaliation in employment; to define those
terms; and to set forth a procedure for investigating and resolving internal complaints.
The City encourages all covered individuals to report —as soon as possible— any
conduct that is believed to violate this Policy.
II. POLICY
The City has zero tolerance for any conduct that violates this Policy. Conduct
need not arise to the level of a violation of law to violate this Policy. Instead a
single act can violate this Policy and provide grounds for discipline or other
appropriate sanctions. Disciplinary action or other appropriate sanction up to
and including termination will be instituted for prohibited behavior as defined
below.
Harassment or discrimination on the basis of race, religion, color, sex (including
gender, gender identity, gender expression, transgender), sexual orientation
(including heterosexuality, homosexuality, and bisexuality), national origin, ancestry,
citizenship status, marital status, pregnancy, age, medical condition, genetic
characteristics or information, military and veteran status, physical or mental
disability, or any other protected classification as defined below, will not be tolerated.
This Policy applies to all terms and conditions of employment, including, but not
limited to: hiring, placement, promotion, disciplinary action, layoff, recall, transfer,
leave of absence, compensation, and training.
Any retaliation against a person for filing a complaint or participating in the complaint
resolution process is prohibited. Individuals found to be retaliating in violation of this
Policy will be subject to appropriate sanction or disciplinary action up to and including
termination.
Attachment A
CITY OF ROHNERT PARK
CITY COUNCIL POLICY
SUBJECT
POLICY AND COMPLAINT PROCEDURE AGAINST
HARASSMENT, DISCRIMINATION AND
RETALIATION
Definitions
POLICY NO, I RESO. NO
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PAGE 2OF9
A. Protected Classifications: This Policy prohibits harassment or discrimination
because of an individual's protected classification. "Protected Classification"
includes race, religion, color, sex (including gender, gender identity, gender
expression, and transgender), sexual orientation (including heterosexuality,
homosexuality, and bisexuality), national origin, ancestry, citizenship status,
marital status, pregnancy, age, medical condition, genetic characteristics or
information, military and veteran status, physical or mental disability, or any
other category protected by federal or State law. For purposes of this Policy,
Protected Classification includes: 1) an individual's protected classification; 2)
the perception that an individual has a protected classification; or 3) the
individual associates with a person who has or is perceived to have a
protected classification.
B. Policy Coverage: This Policy applies to all elected or appointed officials,
officers, employees, contractors, unpaid interns, or volunteers.
C. Discrimination: Treating individuals differently because of the individual's
protected classification as defined in this Policy.
D. Harassment: Unwelcome verbal, visual, or physical conduct based on an
employee's membership in a legally protected category that creates an
intimidating, offensive, or hostile work environment or that interferes with work
performance. Harassment includes, but is not limited to, the following types of
behavior that is taken because of a person's protected classification. Note that
harassment is not limited to conduct that City's employees take. Under certain
circumstances, harassment can also include conduct taken by those who are not
employees, such as elected officials, appointed officials, persons providing
services under contracts, or even members of the public:
1) Speech, such as epithets, derogatory comments or slurs, and
propositioning on the basis of a protected classification. This might
include inappropriate comments on appearance, including dress or
physical features, gender identification, or race - oriented stories and
jokes.
2) physical acts such as assault, impeding or blocking movement, offensive
touching, or any physical interference with normal work or movement. This
includes pinching, grabbing, patting, propositioning, or making explicit or
implied job threats or promises in return for submission to physical acts.
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3) isaaaN acts such as leering, derogatory posters, cartoons, emails, pictures,
or drawings related to a protected classification.
E. Sexual Harassment: Sexual advances, requests for sexual favors, or visual,
verbal, or physical conduct of a sexual nature when: (1) submission to such
conduct is made a term or condition of employment; or (2) submission to or
rejection of such conduct is used as a basis for employment decisions affecting
the individual; or (3) such conduct has the purpose or effect of unreasonably
interfering with an employee's work performance or creating an intimidating,
hostile or offensive working environment. This definition includes potential forms
of offensive behavior. The following is a list of some examples:
Unwanted sexual advances.
2. Offering employment benefits in exchange for sexual favors.
3. Making or threatening reprisals after a negative response to sexual
advances.
4. Visual conduct, such as leering, making sexual gestures, displaying
of sexually explicit jokes, comments about an individual's body or
dress.
5. Verbal sexual advances or propositions.
6. Verbal abuse of a sexual nature, graphic verbal commentary about
an individual's body, sexually degrading words to describe an
individual, suggestive or obscene letters, notes, or invitations.
7, Physical conduct, such as touching, assault, impeding, or blocking
movements.
8. Retaliation for reporting harassment or threatening to report
harassment.
Sexual harassment can occur between members of the same or opposite sex.
Sexual harassment need not be motivated by sexual desire. Sexual harassment
on the job is prohibited whether it involves co- worker harassment, harassment by
a supervisor or manager, harassment by a subordinate, or harassment by third
parties doing business with or for the City.
CITY OF ROHNERT PARK
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F. Guidelines for Identifying Harassment: To help clarify what constitutes
harassment in violation of this Policy, use the following guidelines:
1) Harassment includes any conduct which would be "unwelcome" to an
individual and which is taken because of the recipient's protected
classification.
2) It is no defense that the recipient appears to have voluntarily "consented" to
the conduct at issue. A recipient may be reluctant to protest for many
legitimate reasons, including the need to avoid being insubordinate or to
avoid being ostracized.
3) Simply because no one has complained about a joke, gesture, picture,
physical contact, or comment does not mean that the conduct is welcome.
Harassment can evolve over time. The fact that no one is complaining now
does not preclude anyone from complaining if the conduct is repeated in the
future.
4) Even visual, verbal, or physical conduct between two employees who
appear to welcome the conduct can constitute harassment of a third party
who observes the conduct or learns about the conduct later. Conduct can
constitute harassment even if it is not explicitly or specifically directed at an
individual.
5) Conduct can constitute harassment in violation of this Policy even if the
individual engaging in the conduct has no intention to harass. Even well -
intentioned conduct can violate this Policy if the conduct is directed at, or
implicates a protected classification, and if an individual of the recipient's
same protected classification would find it offensive (e.g., gifts, over
attention, endearing nicknames).
G. Retaliation: Any adverse conduct taken because of any report of harassment
or discrimination, or because of participation in the complaint and investigation
process described herein, is prohibited. "Adverse conduct" includes but is not
limited to: taking sides because an individual has reported harassment or
discrimination, spreading rumors about a complaint, shunning and avoiding an
individual who reports harassment or discrimination, or real or implied threats of
intimidation to prevent an individual from reporting harassment or
discrimination. Individuals that are protected from retaliation include: those who
make good faith reports of harassment or discrimination, and those who
CITY OF ROHNERT PARK
CITY COUNCIL POLICY
SUBJECT POLICY NO. � RESO. NO, Y EFF. DATE a PAGE 5 OF 9
POLICY AND COMPLAINT PROCEDURE AGAINST AUGUST 12, 2015
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associate with an individual who is involved in reporting harassment or
discrimination or who participates in the complaint or investigation process.
Complaint Procedure
A, Anyone who believes he or she has suffered harassment, discrimination, or
retaliation may make a complaint verbally or in writing with any of the following.
There is no need to follow the chain of command:
1) Immediate supervisor;
2) Any supervisor or manager within or outside of the department;
3) Department head;
4) Director of Human Resources; or
5) City Manager
B. Any supervisor, manager, or department head who receives a harassment,
discrimination, or retaliation complaint should notify the Director of Human Resources
immediately.
C. Upon receiving notification of a harassment, discrimination, or retaliation
complaint, the Director of Human Resources shall:
1) Authorize and supervise the investigation of the complaint and /or
investigate the complaint. The investigation will include interviews with: 1)
the complainant; 2) the accused party; and 3) other persons who have
relevant knowledge concerning the allegations in the complaint.
2) Review the factual information gathered through the investigation to
determine whether the alleged conduct constitutes harassment,
discrimination, or retaliation giving consideration to all factual information, the
totality of the circumstances, including the nature of the conduct, and the
context in which the alleged incidents occurred.
3) Report a summary of the determination as to whether harassment,
discrimination, or retaliation occurred to appropriate persons, including
the City Manager, the complainant, the accused party, the supervisor,
and the department head. If discipline is imposed, the level of discipline
will not be communicated to the complainant.
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CITY COUNCIL POLICY
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4) If conduct in violation of this Policy occurred, take or recommend to the
City Manager prompt and effective remedial action. The remedial action
will be commensurate with the severity of the offense, as well as in
consideration of any prior offenses.
5) Take reasonable steps to protect the complainant from further
harassment or discrimination.
6) Take reasonable steps to protect the complainant from retaliation as
a result of communicating the complaint.
D. The City takes a proactive approach to potential Policy violations and will
conduct an investigation if its officers, supervisors, or managers become aware
that harassment, discrimination, or retaliation may be occurring, regardless of
whether the recipient or third party reports a potential violation.
E. Option to report to outside administrative agencies: An individual has the
option to report harassment, discrimination, or retaliation to the U.S. Equal
Employment Opportunity Commission (EEOC) or the California
Department of Fair Employment and Housing (DFEH). These
administrative agencies offer legal remedies and a complaint process. The
nearest offices are listed in the government section of the telephone book
or employees can check the posters that are located on employer bulletin
boards for office locations and telephone numbers.
ALL EMPLOYEES SHOULD NOTE THAT THE FAILURE TO USE THE CITY'S
COMPLAINT PROCEDURE MAY HAVE AN ADVERSE EFFECT ON ANY CLAIM
UNDER THIS POLICY WHEN SUCH CLAIMS ARE LITIGATED.
Confidentiality
Every possible effort will be made to assure the confidentiality of complaints made
under this Policy. Complete confidentiality cannot occur, however, due to the need
to fully investigate and the duty to take effective remedial action. As a result,
confidentiality will be maintained to the extent possible. An individual who is
interviewed during the course of an investigation is prohibited from discussing the
substance of the interview, except as otherwise directed by a supervisor or the
Human Resources Director. Any individual who discusses the content of an
investigatory interview will be subject to discipline or other appropriate sanction. The
employer will not disclose a completed investigation report except as it deems
CITY OF ROHNERT PARK
CITY COUNCIL POLICY
SUBJECT I POLICY NO. I RESO. NO.
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(M]
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necessary to support a disciplinary action, to take remedial action, to defend itself in
adversarial proceedings, or to comply with the law or court order.
Responsibilities
Managers and Supervisors are responsible for:
1. Informing employees of this Policy.
2. Modeling appropriate behavior.
3. Taking all steps necessary to prevent harassment, discrimination, or
retaliation from occurring.
4. Receiving complaints in a fair and serious manner, and documenting steps
taken to resolve complaints.
5, Monitoring the work environment and taking immediate appropriate action to stop
potential violations, such as removing inappropriate pictures or correcting
inappropriate language.
6. Following up with those who have complained to ensure that the behavior has
stopped and that there are no reprisals.
7. Informing those who complain of harassment or discrimination of his or her
option to contact the EEOC or DFEH regarding alleged Policy violations.
& Assisting, advising, or consulting with employees and the Human
Resources Director regarding this Policy and Complaint Procedure.
9. Assisting in the investigation of complaints involving employee(s) in their
departments and, if the complaint is substantiated, recommending appropriate
corrective or disciplinary action in accordance with employer Personnel Rules,
up to and including discharge.
10, Implementing appropriate disciplinary and remedial actions.
11. Reporting potential violations of this Policy of which he or she becomes aware,
regardless of whether a complaint has been submitted, to the Human
Resources Department or the department head.
12. Participating in periodic training and scheduling employees for training.
Each elected or appointed official, officer, employee, contractor, unpaid I ntern and
volunteer is responsible for:
1. Treating others with respect and consideration.
2. Modeling appropriate behavior.
3. Participating in periodic training when provided.
4. Fully cooperating with the City's investigations by responding fully and truthfully
to all questions posed during the investigation.
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CITY COUNCIL POLICY
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5. Maintaining the confidentiality of any investigation that the City conducts by
not disclosing the substance of any investigatory interview, except as
directed by the department head or Human Resources Director.
6. Reporting any act he or she believes in good faith constitutes harassment,
discrimination, or retaliation as defined in this Policy, to his or her immediate
supervisor, or department head, or Human Resources Director.
7. Employees have a duty to disclose any benefits received. Employees are
hereby informed that no supervisor, manager, or officer of the City, or other
person or entity doing business with the City, is authorized to expressly or
impliedly condition the receipt or denial of any benefit, compensation, or other
term or condition of employment on an employee's acquiescence to any sexual
demand. To the contrary, all employees are instructed that they must refuse
such demands and report them promptly either to a supervisor, manager, or
department head. Any employee who is found to have accepted any benefit
from the City because he /she submitted to an unreported sexual demand will be
disciplined appropriately, including but not limited to, reimbursement for the
value of any benefits received. Any employee making such a demand will be
similarly disciplined.
Dissemination of Policy
All employees shall receive a copy of this Policy when they are hired. The Policy may
be updated from time to time and redistributed.
SUBJECT
CITY OF ROHNERT PARK
CITY COUNCIL POLICY
T ..POLI.C... . b -_ n
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2015 -131
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EFF. DATE
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Acknowledgment of Policy and Complaint Procedure Against Harassment,
Discrimination and Retaliation
PAGE 9OF9
I have received the City of Rohnert Park Policy and Complaint Procedure Against
Harassment, Discrimination and Retaliation. I have read the policy; I understand it and
understand the rights and responsibilities I have under the policy. I accept responsibility
for adhering to the policy. I understand that violations of the policy may result in
disciplinary action as provided for in the City's Personnel Rules, up to and including
termination.
Employee Full Name:
Employee Signature:
Date: